Professional Documents
Culture Documents
By
Alison Voight
Gary Robb
Jennifer Skulski
Deborah Getz
Debbie Scharven
Best Practices of Accessibility in Parks and Recreation
Introduction
While the Americans with Disabilities Act (ADA) of 1990 has led to greater access to
employment, transportation, public services and public accommodations for people with
disabilities, some of the esoteric regulations related to program access have been more
challenging to apply to public park and recreation settings. For the practitioner, it has not been
easy to translate the abstract concept of “program access” into practice. Federal accessibility
standards for buildings and facilities exist and continue to evolve with very specific scoping and
technical provisions. These standards can be applied to the design and construction of recreation
facilities, visitor centers and even outdoor areas for recreation. However, the requirements for
“program access” under Title II of the ADA are not as specific. This often leaves park and
recreation professionals to their own accord to make programmatic and administrative decisions
based on what information is readily available to them at the time. The “program access”
standard requires entities to either modify their policies, practices and procedures, or provide
auxiliary aids and services to ensure access for people with disabilities. Program access includes
access to goods, services, activities or any other offering of a federal, state and local government
or business. “Programs” under the program access standard do not necessarily have to be
structured or staffed. Programs could range from structured and staffed tennis lessons to an
unstructured walk along a nature trail with wayside exhibits. While federal technical assistance
materials provide some examples of program access for guidance, the concept of program access
is still quite abstract. Moreover, what constitutes accessible “programs” or the “best practice” to
ensure persons with disabilities will have equal access to recreation and leisure programs, has
become increasingly more complex and difficult to ascertain, as the demand for inclusive
recreation programs continues to grow. Best practices in accessibility, as defined for the
purposes of this study, are: those common, identifiable procedures, attitudes and behaviors,
which exceed the minimum standard represented in the practice and delivery of accessible
Striving to deliver accessible recreation and leisure programs that exceed minimum
accessibility standards is often difficult for professionals to implement. The literature is limited
to ADA technical assistance manuals issued by the U.S. Department of Justice with few
examples related to recreation. To date, there has been a lack of documentation emphasizing a
best practices approach which goes above and beyond the minimum requirements to achieve a
greater degree of accessibility that results in full inclusion of people with disabilities. In
addition, many recreation and park personnel have little or no background or training in how to
accommodate persons with disabilities. Exceeding the minimum accessibility standards for
physical access to accommodate the widest spectrum of users and their various abilities is
considered universal design. As such, principles of universal design have emerged and provide a
foundation for practitioners and educators. An exemplar in universal design may use one or all
seven of the principles of universal design. While universal design pushes the envelope of
accessible design in the concrete, physical, built environment, it could be hypothesized that best
practices guide the more abstract concept of program access for a comprehensive accessibility
According to the U.S. Census Bureau (2002-2006), there are an estimated 52 million
Americans with at least one disability. This means that one in five Americans has a physical or
mental impairment that substantially limits him or her in one or more major life activities. For
park and recreation managers and administrators, it is critical that they understand the
accommodate the 20 percent of the U.S. population that could be disabled and visiting their
parks or participating in their recreation programs. Consequently, any failure on the part of the
accommodation, not only has a negative impact on the individual with a disability, but also
impacts the family members and friends who may accompany the individual to the recreational
opportunity.
1992 with the directive to provide training, technical assistance and research on the inclusion of
people with disabilities in parks, recreation and tourism. Thousands of professionals throughout
the United States and abroad have utilized NCA for assistance with program access issues that
arise at their programs and facilities. Over the last five to 10 years, the NCA professional staff
has witnessed a dramatic shift in attitudes toward the implementation of the ADA regulations.
After the ADA was passed, there was a degree of negative perception amongst practitioners
where the regulations were viewed as an unfunded mandate with unrealistic timelines and
compliance procedures. Most resistance was embedded in fear and lack of understanding on
what accessibility meant (NCA, 2007). According to NCA training course instructors and
accessibility specialists, a significant shift in attitudes has emerged where the negative perception
is no longer as prevalent and practitioners are more likely to seek best practices not solely
because compliance is the law, but because full inclusion of people with disabilities is the right
thing to do to promote health and wellness and build strong communities (NCA). More and
more, recreation professionals contact NCA already armed with information on the minimum
compliance requirements, but are now seeking information on best practices that exceed the
minimum requirements, and are therefore more likely to achieve full inclusion. The need for
specific information regarding the best method or that which exceeds the minimum standard has
warranted this research study. Currently, no formal document with best practices information
exists for practitioners seeking to exceed the minimum compliance requirements set forth under
the ADA and other disability-related legislation. As a result of frequent inquiries regarding best
practices from practitioners, NCA initiated this research study in order to ascertain which
practices in the field of parks and recreation accessibility management exceed the minimum
standards set forth by the ADA and other disability-related legislation. The final purpose of the
research was to create a document that details “best practices” in the delivery of recreation and
leisure service in a variety of settings. The study was coordinated by NCA with support from
faculty and staff from the Department of Recreation, Park and Tourism Studies and the Eppley
Methodology
management that exceed the minimum standard, a national panel of experts was assembled. The
experts were selected according to their national profile as professionals in the fields of
accessibility, disability, and/or recreation services. A total N of 26 experts was originally selected
to participate in a modified Delphi survey consisting of four rounds of query. Of those that were
able to participate in the study, 15 had more than 20 years experience, two had 11-15 years
experience, and only one participant had less than 10 years experience. The panel’s expertise
ranged from community recreation and therapeutic recreation to legal compliance. Their major
accessibility/ADA/504 coordinator (3), program manager (3), consultant (2), technical assistance
director (1), and engineer (1). The panel also represented various organizations including federal
agencies (8), state government (1), local/municipal government (1), not-for-profits (3), private
business (1), and university/colleges (4). The panel consisted of individuals from ADA resource
centers, enforcement and rulemaking entities, land management bureaus, recreation providers,
A modified Delphi process was selected as the best means of soliciting and analyzing data
from the panel of experts. The Delphi process is a method used for creating communication
between panel members for the purpose of discussing complex issues, using informed judgment,
to ultimately form a consensus regarding the issues (Dalkey, 1969; Linstone & Turoff, 1975).
The modified Delphi process extends the main Delphi definition where the group panel is forced
to think about the subject in a more complex way (Weaver, 1972). The modified Delphi process
allows all the panel experts to reevaluate and refine their responses to certain questions during
The panel of experts was asked to volunteer their time as participants in an estimated four
rounds of surveys. The total time was estimated at 2 hours (Round 1 taking approximately 30
minutes, and Rounds 2-4 approximately 15 minutes each). Approximately two weeks were
allotted between each round, except for the third round, where an extra week was given. The
survey was delivered online through a survey tool administered by the Eppley Institute. In this
particular study, the question examined was, “What constitutes ‘best practices’ in accessibility in
recreation and park environments?” In the first round the participants were asked to agree or
disagree to 12 original best practices, proposed by the research team, for accessibility in
recreation and park settings and to provide rationale for their response. (See Appendix A for the
original survey questions and original 12 proposed best practice statements.) After the 12 best
practices were reviewed, the participants were then asked to identify any additional best practices
In the second and subsequent rounds, the participants were asked to rate the original best
practices and those proposed by the participants for which consensus had not been reached.
Consensus was defined as an agreement of 80 percent or higher. After consensus was reached
the participants were not asked to consider the best practice again.
The total timeline for the modified Delphi process took approximately five months to
complete all four rounds of questions. Any best practice statement where consensus was not
reached was sent back to the panel, along with all the comments that were provided in the
previous round.
Data Analysis
Eighteen of the 26 identified experts participated in Round One of the modified Delphi
survey. In order for an 80% consensus to be reached on each best practice item, 14 of the 18
content experts would have to agree on each of the 12 best practices given. According to data
results, consensus was reached on all but three of the original 12 best practice did not have an
80% consensus from the panel of content experts. (See Appendix B for Round One data analysis
results.)
Round Two of the modified Delphi survey consisted of three of the original best practice
items listed previously, from Round One, where consensus was not reached, and nine new best
practice items suggested from the panel. (See Appendix C for Round Two responses). The
number of participating subject panel experts dropped from 18 in the original Round One to a
total N of 14 participants. The threshold for consensus among the 14 participants, for each best
The total number of panel experts participating in Round Three was 12. A total of eight
best practice items were sent to the subject panel experts for review and discussion. (See
In Round Four, the panel of experts totaled nine participants. The panel did not reach
consensus on any of the six items from Round Three. (See Appendix E for Round Four results).
Based on the non-consensus items from Round Four, a total of 13 best practices in accessibility
evolved from the modified Delphi study. Table 1 shows the final 13 best practices in
The modified Delphi process allowed the expert panelists to comment on each proposed
item by giving examples of the best practice, as well as rationale for why the item should or
This best practice would suggest that traditionally written information is available in audio
format for persons with visual impairments; traditionally audio information is available in
written format for people who are deaf or hard of hearing; and that all information is presented in
clear and concise formats, including tactile experiences, for persons with a range of cognitive
impairments. The expert panelists gave examples of alternative formats such as captioning on
audio presentations in the park visitor center; complimentary alternatives to written exhibit
information that can also be available in audio format; and providing a tactile relief map of the
park that people can touch. The implementation of this best practice would also suggest that
information provided in multiple modes or formats can benefit a wider range of people, and not
just people with disabilities. Large print could benefit the aging population, as well as young
children learning to read, while the same information provided in clear, concise language could
benefit people with cognitive disabilities, and individuals learning English as a second language.
The provision of the exhibit information through an audio tour would benefit not only people
with visual impairments but also those individuals that could become preoccupied such as
One expert panelist gave the example and rationale, “The accessibility standards/guidelines
should be exceeded to the extent possible in all design. For instance, whenever possible,
entrance ramps should be designed to exceed the minimum 1:12 standard, making it longer, less
steep and, subsequently, easier for a greater number of people to use.” Another panelist added,
“In a program context, our agency frequently exceeds the minimum Title II requirements by
regularly providing one-to-one program aides (which DOJ says isn’t necessarily required). This
summer we have hired a nurse of a boy with autism and diabetes. In both situations, our
rationale is the same: without the one-to-one aide or nurse that person cannot enjoy the
recreation [experience].” A third panelist summarized the rationale for the best practice by
stating, “To merely comply with the law means that the total range of individuals with disabling
conditions, who would not necessarily identify themselves or be identified as "disabled" by legal
definition, are cut out of participation and inclusion. Going beyond compliance means viewing
accessibility as an asset to the institution and as basic good customer service. This is the most
3. A best practice in accessibility includes an established set of policies which facilitate and
promote inclusive and accessible programs, and facilities, in the delivery of recreation and
leisure services.
Comments from this item suggest that an established set of policies is necessary to serve as
guidance for staff, and ultimately, to measure the agency’s success/failure to promote inclusive
and accessible programs and facilities. One panelist commented, “Having established policies in
place, taught at initial entry into a position, and referred to often affirm the importance of
accessibility, directs employees on methods of implementation, and informs the public about
what people have the right to expect.” Another panelist commented that a lack of established
policies can lead to confusion among staff and those with accessibility management
responsibilities, which in turn can result in bad choices for the agency.
Panelists believed that training was necessary to introduce new information and reinforce
relevant information for employees and volunteers. One of the expert panelists tied the
importance of this item to the previous item by stating, “It does an agency/institution no good to
have accommodations, policies and procedures if those individuals who must implement them
This proposed best practice was the first of two items to receive 100 percent consensus from the
expert panel. The range of comments suggested that the inclusion of people with disabilities in
an advisory board capacity could bring personal experiences to the group, new insights that
could result in better decisions, credibility and greater support from the community. A panelist
suggested, “Having a group that is knowledgeable and has experience in areas of accessibility
related to the agency is important when making changes to program structures, adding new
programs, entering into joint ventures with other agencies, creating new facilities, updating
marketing strategies and materials.” Comments from the expert panelists included whether or
not the advisory board should have a broad or narrow focus. However, there were a number of
comments suggesting that the advisory board should have a function and purpose, prohibiting it
from serving as a “token effort to rubber stamp access decisions that have already been made.”
Comments from this item illustrated how support by administrators can affect the organizational
philosophy, culture and approach toward accessibility and inclusion of people with disabilities.
“If the manager doesn’t fully believe in inclusion, staff won’t either and will do it poorly,”
commented one panelist. Another added, “Only when administrators make access policy and
require full integration does permanent, dependable access occur.” Several panelists connected
demonstrated support by administrators to the financial planning and budgeting processes for
inclusion support, retrofits and accessibility improvements. One panelist commented, “The
agency budget should reflect support for accessible recreation programs through specific line
item funding of accessibility projects.” Panelists alluded to the fact that if there was no support
from administrators for accessibility and inclusion, it would not receive the necessary budgetary
and staff resources for implementation and, as a result, accessibility would not be viewed as a
priority compared to other issues, ultimately leading any accessibility efforts to fail.
7. A best practice in accessibility promotes the delivery of integrated recreation programs and
activities for persons with and without disabilities if applicable, feasible, or desirable.
experiences. Said one panelist, “Integrated programming acknowledges that all people have
varied learning styles, different levels of understanding and experience in different subject areas,
and usually come to recreation programs with family and friends who are at different levels or
may have different disabilities than they do. Integration is both the most educationally sound
and cost-effective approach to programming.” Panelists felt that programming emphasis should
be placed on making existing programs and experiences accessible to the widest audience
8. A best practice in accessibility includes marketing materials and program brochures that
are accessibility-oriented for the promotion of inclusion of persons with disabilities.
Expert panelists felt that if enough detail was provided on the accessibility features of the
program or facility, people with disabilities would have adequate information to make a more
informed decision regarding their ability to participate in the program or facility. This could be
done through the general program/facility brochure, a brochure specific to accessibility features,
or even a special accessibility section of the agency/facility web site. For example, a
campground brochure might include information on the type of accessible camp sites, location
and proximity to the accessible shower facilities. A museum web site might include information
on the availability of audio described tours, or sign language interpreters, and contact
information on how to request a more specific accommodation for a museum visit. Some
panelists also suggested that the use of testimonials and photos of people with disabilities
enjoying the program or facility could market a positive message about the agency’s
9. A best practice in accessibility includes recruiting staff and volunteers with disabilities to
develop and deliver public programs.
The expert panelists suggested that the inclusion of staff and volunteers with disabilities is a
universal best practice where the agency profile should reflect the profile of the community it
serves. They added that qualified individuals with disabilities will be able to contribute to
program planning and design based on their personal experiences, while at the same time, they
may be able to help others with, and without, disabilities to feel more comfortable participating
in the program.
10. A best practice in accessibility fosters an organizational culture and attitude where
recreation staff recognizes and promotes the rights of all persons to access fulfilling and
enjoyable recreation activities, regardless of ability or disability.
This item concludes that the agency’s core values should include a philosophy toward inclusion
suggests that support of inclusion should be a responsibility of all staff as specified by their job
description. Some panelists commented on how fostering a positive culture can be challenging if
it is a philosophy that is only practiced by a few people in the organization and when/if there are
staff changes, this practice may or may not be carried forward depending upon the new
individuals in the positions. This reiterates the need for of philosophy of accessibility to be part
of the organizational culture and best practice, and not necessarily just a practice of a few
11. A best practice in accessibility includes expenditures related to the purchase of adapted
equipment, services, and/or accessibility improvement projects in the financial planning
and budgeting process.
This item emerged as a theme in Round One, and when presented as a proposed best practice in
Round Two, it was the second of only two items to receive 100 percent consensus. Comments
from this item suggests that planning for accessibility is more cost-effective when adapted
equipment, services and accessibility improvements are considered as part of the original
planning process and not as afterthoughts. Prioritization of funding for specific projects or
12. A best practice in accessibility includes public programming that reflects the diversity of
communities to include people with disabilities.
While some expert panelists viewed this practice as a “no brainer” that should be common place
among practitioners, others saw more global implications. One panelist commented, “A narrow
view of best practice would see accessibility isolated from other practices. It is important to see
and encourage the interrelated nature of accessibility with events that expand community
awareness of its diversity. Fundamentally we are talking about human differences and what
communities believe and do in regard to acceptance and inclusion. This potentially impacts local
13. A best practice in accessibility includes a policy to exceed minimum scope of requirements.
One panelist remarked, “Best practices always exceed minimum requirements. That is what
makes them exemplary.” This item evokes comments on the assumed correlation between best
practices in accessibility with best practices of Universal Design. Another panelist suggested
that policies that support Universal Design go above the minimum standard and this is what
There were a total of eight best practice items presented that did not receive consensus by
the panel. Two items that did not reach consensus as best practice by the panel of experts
focused on the “undue burden” provision in the ADA as a reason for not making programs
and/or facilities accessible for persons with disabilities. Specifically, the two items were stated
as follows:
1. A best practice in accessibility includes the goal that recreation and leisure programs
are accessible for persons with disabilities, unless an undue burden is imposed on the
agency.
2. A best practice in accessibility includes the goal that the majority of the facility
(building) is accessible for persons with disabilities, unless an undue burden is imposed
on the agency.
In both cases, panelists indicated quite strongly that the use of the “undue burden” provision was
not appropriate when considering best practice. Panelists reiterated that undue burden is a term
used as a legal defense and that it did not constitute best practice, rather only meeting minimum
requirements.
It is interesting to note that these two items had over a 50 percent consensus as best
practice in Round One, but only 14 percent in Round Two. It is obvious that comments by other
panelists had a significant influence, so much so that in Round Two, 86 percent of the responses
were negative, thus dropping the items from consideration in subsequent rounds. This indicates
that the panelists were influenced by the comments of others within the Delphi process, and that
The third item originally proposed by the research team went through all four rounds of
the process and did not reach consensus. In fact, the ratings changed very little through the four
rounds, with those favoring, and those opposing the statement as a best practice, was evenly
Those disagreeing with this statement did so largely because of a) they felt it was a minimum
requirement and b) they were concerned about the wording in the statement, specifically using
the words “reasonably accommodate.” While this statement did not reach consensus it was not
so much that the panelists disagreed with the content, but with the wording and because it is a
minimum requirement.
Those agreeing with the statement looked at it quite differently, citing examples of
specific venues, equipment and services that may not be interpreted as being required by the law,
but by doing so, would elevate the provision of these services to best practice. Additionally,
those supporting this statement indicated that when agencies provide as many accessible features
as possible, beyond the minimum requirements (e.g. Universal Design) they are using best
practice.
The following five items were proposed best practices generated by the panel in Round
One and presented for consideration in Round Two. The following were items generated by the
Over half of the experts agreed with this statement, and there was not much change in the three
rounds in which it was rated. The item did not reach the 80 percent consensus threshold. Some
panelists, once again, got “hung up on” semantics (such as the use of the word
“accommodation”). This was the primary reason the panel did not reach consensus. The word
“accommodate” was used in the survey in the generic sense, and was not meant to be confused
with how the word is used in the ADA. Unfortunately, it did create issues that influenced the
outcome of the study. It is also interesting to note that some of the panelists did not agree with
this statement because of the assumption that the research did not include people with
disabilities. There was nothing in the statement that would have suggested that. Those agreeing
with the statement stated that collecting objective data was important for agencies to continue to
strive for best practice. They indicated it was particularly important in shaping policy and
Almost two-thirds of the panel agreed with this statement on the first two rounds, but those
agreeing dropped to under 50 percent in the final round. Those agreeing that this was a best
practice statement cited that it was necessary in order for people not to become dependent on
adaptations, and that too often adaptations are used when they are unnecessary. On the other
hand, those opposing this statement as a best practice, mentioned the permanency of disability,
therefore phasing out adaptations is not an option, and that it is a dangerous concept.
Again, in this question, it was evident that panelists viewed the statement differently and with
different frames of reference. Some chose not to respond to the broad meaning of the statement
but only to a narrow interpretation. In this case it is likely that this statement would have
This item received just under 50 percent favorable vote on the first two rounds and just over 50
percent in favor on the last round. Those supporting the statement indicated that this definitely
exceeds the minimum and that it is needed to make best practice adjustments in programs and
facilities. Those voting against it as a best practice did not disagree on the need to conduct
surveys, and felt that “ongoing surveys were important.” However, there were differences of
opinion as to how often surveys were undertaken. The specific time listed was likely the major
7. A best practice in accessibility includes one person designated to have the authority to
provide, modify, and assist staff in provision of services and receive complaints.
This item generated many comments and much disagreement among panelists. Essentially the
disagreements revolved around the concept that it is very important to have an identified person
who is visible to the public, and who does not have to wade through many administrative layers
to get accessibility projects completed. The other perspective was that having one person as the
authority was a dated practice, and that it was important to have many people involved in
decision-making on accessibility.
This item missed receiving a consensus vote from the panel by 1 percent in the first round and 2
percent in the final round. Those disagreeing that this statement was best practice did so because
they did not know what “information about people with disabilities” meant or that they did not
understand how including information would make them accessible. On the other hand, the
majority of panelists felt that it was a best practice statement because a) including the
information about the availability of accessible seating, listening devices, captioning, etc., not
only provides assurance to people with disabilities but is a good way for the public to understand
that all people are welcomed; and b) the inclusion of information about people with disabilities
enhances the inclusion of all people into these programs and venues.
Discussion
The following list describes several of the challenges that the Research Team at Indiana
1. The Panel of Experts was selected by the Research Team at Indiana University. The panel
members needed to have a minimum of five years of experience in the recreation, inclusion
and/or accessibility field and a demonstrated understanding of the laws and issues related to
access for people with disabilities. The Research Team attempted to identify individuals who
2. The response rate of the panel dropped by 50% from Round 1 to Round 4 and therefore
indicates that a few of the items may have reached consensus had some of the wording been
A total of 21 possible “best practices in accessibility” were identified by the research team
and the panel of experts. Of the twelve statements originally proposed by the research team as
best practices, nine were agreed upon by the panel as “best practices.” All nine were accepted as
best practices by the panel of experts on the first round of the Delphi process. Of the nine
additional statements proposed by panel members, four of these were ultimately determined to be
“best practices” by the panel. Two of these four were accepted by a consensus of the panel the
first time they had the opportunity to rate them. Two of the four accepted items took two rounds
of consensus building to reach the best practice threshold. As stated earlier, the research team had
set eighty percent (80%) consensus as the threshold for accepting the statement as a best practice.
It is important to note that in most cases, the items that did not reach consensus by the panel, did
not reach that threshold for the following reasons, as stated by panelists:
minimum expectation (core principle of an agency) and therefore should not be identified as
best practice.
2. The item(s) were generally agreed to as best practice but were not included because panel
members felt that there were one or more “words” in the descriptions (semantics) that
members seemed to interpret this question differently than others, based on “wording and
not concept.”
3. The two items that included “undue burden” as a reason to not comply with accessibility
was generally viewed as an illegitimate reason to not provide accessibility, and using it as a
whether or not it should be included as a best practice. In both cases, each item received
less than 50% agreement by the panelists as best practices, primarily for the following
reasons:
dependency
As a research technique, the Delphi has been successfully used by researchers to reach
consensus among experts on issues where the opportunity for face-to-face dialogue may not be
practical. In this study, it does appear that sharing expert opinion among panelists did influence
decisions on a few of the survey items. It appeared that the most influential aspect of the process
was the panelists’ ability to review other responses and to clarify or add to the thoughts of the
group. On at least five items, based on ratings and expert comments, other panel comments did
appear to influence ratings on subsequent rounds of the study. However, only two items moved
over the 80% threshold to qualify them as a best practice. Because the number of experts
participating in each round was lower, it is difficult to measure the cumulative effect of expert
Conclusion
This study should be considered the first of many that could explore the concepts and
guiding principles for further defining best practices of accessibility in parks and recreation. As
practitioners, consumers and researchers review the 13 best practices presented here, it is likely
that they will find many that could be considered common practice and intuitive to establishing a
successful accessibility management program. It is also important to note that the broad language
used to describe the 13 best practices could enable these to be applied to industries outside the
fields of recreation, park and tourism administration. Future research is needed to investigate the
broad application of the best practices, or narrow benchmarks that could measure outcomes as a
References
Americans with Disabilities Act (1990). Title II and Title III regulation. Washington, D.C: U.S.
Department of Justice.
Dalkey, N.C. (1969). An experimental study of group opinion: The Delphi method. Futures,
1(5), 408-426.
Linstone, H.A., & Turoff, M. (1975). The Delphi method: Techniques and applications.
Weaver, T.W. (1972). Delphi: A critical review. New York: Syracuse University Research
10. A best practice in accessibility includes the goal that100% of programs and
activities delivered are integrated programs for persons with and without
disabilities if applicable, feasible or desireable.
12. A best practice in accessibility includes the goal that the majority of
programs are accessible for persons with disabilities, unless an undue burden
is imposed on the agency.
13. A best practice in accessibility includes the goal that the majority of the
facility (building) is accessible for persons with disabilities, unless an undue
burden is imposed on the agency.
4. A best practice in accessibility includes the provision of accessible information to
patrons, in alternative formats, recognizing persons with visual, hearing, or cognitive
impairments.
Yes, I agree %
16 89%
• Our aging population often needs large print materials to make reading easier.
The burgeoning use of text messages has also been invaluable as a alternative
communication method for people with impaired hearing
• Exhibition labels that are written "reverse pyramid" format: (first line/paragraph)
introductory, clear language, in precise sentences presenting key information on
the object or exhibit; following paragraphs containing increasingly more detailed
information for those who want to read further. Legible label text with label
design facilitating easy reading; label within reading distance/height for viewers
both seated and standing. Label text also available in audio format, either right
at the label location or in a format carried with the viewer.
• All exhibit design must ensure the information is available to and understandable
by persons who may have visual, hearing, or cognitive impairments. For
instance, providing written information in audio format for persons with visual
impairments; providing audio information in written format for deaf or hard of
hearing persons; and providing information in clear, concise formats, including
tactile experiences, for persons with the range of cognitive impairments.
• Providing an audio tape for an exhibit area. Not only provides information to
persons with visual or cognitive impairments, but also to others who may be
preoccupied with other things (I have talked to parents with young children who
prepare audio - allows them to watch their children and still receive info.
• We provide web access, Braille, large print info in audio formats, read and
describe when necessary.
No, I disagree %
•
2 11%
• It's required by law! If an entity is not complying with the ADA if they fail to
provide alternative formats of their programs and services.
5. A best practice in accessibility includes practices that exceed the minimum
standards/guidelines for accessibility established by the Americans with Disabilities Act
Accessibility Guidelines (ADAAG).
Yes, I agree %
17 94%
• Providing a brochure on site which provides information about the slope, cross
slope, surface, etc. of trails.
• While the ADA's Standards for Accessible Design (the enforceable standards
drawn from the ADAAG) give general standards for paths of travel and turning
spaces, the Standards are not specific enough to address issues of trying to
navigate a crowded visitors' center to see exhibition labels, pick up books in the
shop, or maneuver in and out of the theater. Parks and recreation areas must
consider the ADA Standards in the context of their knowledge of crowds,
viewing requirements, viewing heights, and consider providing much larger
spaces than the ADA requires.
• To merely comply with the law means that the total range of individuals with
disabling conditions, who would not necessarily identify themselves or be
identified as "disabled" by legal definition, are cut out of participation and
inclusion. Going beyond compliance means viewing accessibility as an asset to
the institution and as basic good customer service. This is the most inclusive
approach to accessibility.
• Exceed YES, MEET NO! (This is a confusing question since you mix standards and
guidelines (which are different) and they are not "established by ADAAG".
• Make all walkways 60 inches wide. Not only allows comfortable walking room for
everyone, include parents with strollers, but allows owner to "cheat" on
maintenance - bushes growing next to walkway do not have to be trimmed as
often since a 36-inch path should always be available
• Extra accessible parking, more than one accessible restroom stall, having
adapted recreation equipment available for use or rent, such as water skis,
monoskis, hand cycles.
• The minimum standard for a ramp under the ADA is 1/12. Architects and
designers tend to design to the minimum which does not take into account the
spectrum of users. A 1/12 ramp is still difficult to do for many people with
disabilities. A ramp that is 1/15 -1/20 would be more useable to a wider variety of
individuals needs. Not designing to the minimums or maximums rather looking at
spectrum of user and choosing options that will serve greatest # of people
optimum.
No, I disagree %
1 6%
• Exceeding the minimum standards is many cases is exceedingly helpful, but too
many people are falling short of even meeting the standards, so I think that a
"best practice" at this point in time would include meeting the standards.
6. A best practice in accessibility includes an established set of policies which
facilitate and promote inclusive and accessible programs, and facilities, in the
delivery of recreation and leisure services.
Yes, I agree %
16 89%
• Establishing a policy for the provision of auxiliary aids, when requested, to access
programs and services.
• Inclusive to the greatest extent possible, given the person's abilities and
limitations. People are more than just the disability; services are individualized to
the fullest extent possible.
• Our inclusion policy covers everything from how requests for support are made to how we
provide the support to how we fund the support.
• At this point probably an established set of policies would be helpful. For some
organization including and developing accessible programs and facilities is or
will be second nature and policies won't be needed.
measure or guidance on which to base future procedural decisions. This leads to
confusion amongst staff and those who need to implement accessibility
measures which in turn leads to bad choices.
• Have policy that only accessible picnic tables will be purchased or start with a
goal that all campsites will be accessible and back off only when not feasible.
• Programs that are built around the possible inclusion of all different types of
disabilities. Providing interpreter if needed, defining the type of agility needed to
become involved in an activity so those with limitations can self select a hike that
is on a paved trail to allow those with mobility challenges to participate and
stated as a paved trail.
• Practices within a program that would support people who have additional
needs (i.e. assistance to get in/out of pool and/or assistance with clothing
management, communication issues, etc.) to participate within the regular
programming versus referring these individuals to "specialized" programming
strictly because they have a disability. This would include notifying participants
of the availability of accommodations/modifications and training staff to
respond appropriately when requested.
No, I disagree %
2 11%
• This sounds like program or service delivery...not necessarily best practice. The
policies themselves may include some "best practices".
• If the practice is not written down or communicated to staff, policies are not
incorporated into the day to day activities of the facility. I think this is a current
requirement and not necessarily a best practice.
7. A best practice in accessibility includes the establishment of an ongoing, periodic
training program for agency personnel and volunteers regarding accessible and
inclusive concepts and practices for people with disabilities.
Yes, I agree %
16 89%
• Training park staff on the use of beach chairs to provide access into the water for
wheelchair users.
• All summer camp staff will be oriented on inclusive service delivery prior to the
beginning of camp
• The provision of annual training for seasonal staff, who provide direct information
or services to visitors and other participants (i.e. camp counsels, visitor
information desk staff)
• See response to previous question. At this point in our society training is probably
needed. However, I've been encouraged by the different reaction from
participants for training I did 15 years ago to training I've done more recently.
Recent participants have more of an "of course" attitude when discussing the
inclusion of people with disabilities.
• Agency policy should require training programs/sessions for current and new
personnel and volunteers to include sections on accessibility, attitudinal barriers
to people with disabilities, universal design, and accessibility guidelines and
standards.
• The frequency of how often you provide this may be the "best practice".
• Have been at visitor centers where the staff either did not know how to operate
captioned videos or did not know where assistive listening devices were located
(even though they knew that they were available) - periodic training would help
to avoid these issues
• This type of training could only target accessibility for people with disabilities, or
the topic of accessibility and otherwise meeting the needs of persons with
disabilities could be infused into all training topics as appropriate. Topics would
include teaching recreation or sport skills, use of fitness equipment, interacting
with patrons, emergency procedures.
• Regardless of the [proficiency of the staff, training is essential. The standards for
access and inclusion evolve and training on the latest way to include is essential.
New materials for trails, etc.
• Incorporating disability awareness into all orientation materials for staff and
holding a session at least once yearly for all existing staff to review various
policies/practices. This should include sharing best practices that have been
used by employees who have worked with program participants with disabilities
to share strategies and experiences. This decreases fear of the unknown.
No, I disagree %
2 11%
• It is hard to argue against training, but here I respond only to the notion of
ongoing and periodic training. We certainly deliver and receive a lot of training,
but I wouldn't view it as a schedule.
8. A best practice in accessibility includes the establishment of an Accessibility Advisory
Board (or similar group) which includes persons with disabilities.
Yes, I agree %
18 100%
• This is imperative for the initiative to have credibility and relevance. People with
a variety of disabilities should be included.
• Depends on the organization. Again the more ingrained inclusion is the less need
for an accessibility advisory board.
• Agency policy should require the establishment of a local committee (feds can't
call it an Advisory Board) by field offices to consult with the agency on local
design and planning issues. The committee must include persons with disabilities
or their representatives to insure inclusive planning.
• I agree, but only to the extent that the idea of an "advisory board" be quite
broadly defined. The old idea of a standing committee that meets quarterly or
National Center on Accessibility Appendix B - 11
yearly is useless in addressing the immediate needs and concerns that need to
be addressed on a daily basis. In addition, merely having an "advisory board" is
not the same as taking their advice. If having an "advisory board" is a token
effort to rubber stamp access decision already made, or if the advisory boards
advice is treated dismissively and/or never integrated into the broader
agenda/mission/purpose/goals, and/or never presented or considered by the
highest level of management then it is a waste of time, energy and staff
resources. IF - a board or task force, is used to develop and build actual policy
adopted by an agency/institution and/or if they are available for consultation to
deal with daily issues to provide technical consultations, etc. then these groups,
definitely inclusive of people with disabilities in a meaningful and significant way
are absolutely essential to successful best practices in accessibility.
• This is the first thing that sounds like a "best practice". It's not required by law, but
could enhance and improve service delivery. I think entities could benefit from
suggestions on the make-up of such a Board. Too often, entities expect an
advisory board like this to tell them what to do and provide direction on specific
accessibility standards. This works if the person or persons are knowledgeable. If
not, they might suggest that a certain design be used that meets "their" needs
and make the entity vulnerable with respect to compliance.
• This board would not only be able to address issue, but allow promote
awareness. Inclusion of persons with disabilities on this board would allow the
board to address issues with real life answers instead of textbook answers
• Having an advisory board can help an organization make sure that they are
incorporating policies that do not restrict access and review facilities for
compliance.
• Having a blind person on an advisory board will highlight the need for better
audio communication, transportation to recreation facilities.
construction or alterations and when making decisions of budgetary nature that
may affect services (prioritization) when needed. This should not be token only.
There should be real buy-in from the entity leadership and a meaningful role
should be established for this group.
9. A best practice in accessibility includes demonstrated support by administrators
regarding accessible recreation programs.
Yes, I agree %
16 89%
• State of Hawaii Department of Land and Natural Resources' policy for persons
with disabilities who are hunters to be able to shoot from a truck instead of
walking, to the extent that vehicles will not damage the environment and are on
an established route other permitted for maintenance vehicles.
• An agency administrator that hires general programmers with skills and interest in
serving people with disabilities
• Line staff follow the lead of administrative staff and supervisors. When admin not
only professes the value of access and inclusion but leads the discussion and
actively supports it him or herself.
• The provision of a policy providing increased staff ratio for afterschool programs,
which include individuals with disabilities.
• While much can be accomplished by grass roots accessibility efforts, they are
often hit-or-miss, depending on individual staff, and often disappear when the
initiating staff member leaves. Only when administrators make access policy
and require its full integration does permanent, dependable access occur.
• The agency budget should reflect support for accessible recreation programs
through specific line item funding of accessibility projects.
• Providing funds specifically earmarked for accessibility retrofits
• City of Chicago hired a Disability Policy specialist in the park district for the 1st
time and this position is located within the administrative offices and reports
directly to the administrator. This gives a direct line of reporting and
accountability to the issues affecting program participants with disabilities within
the administrative offices versus within a "specialized" program only that has
layers of administrative above it.
No, I disagree %
2 11%
• I believe that this is needed to make sure that programs and facilities are
accessible and useable by all.
10. A best practice in accessibility promotes the delivery of integrated recreation
programs and activities for persons with and without disabilities if applicable, feasible, or
desirable.
Yes, I agree %
15 83%
• Again, service based on larger need, not by disability per se, but by individual,
whenever and wherever possible.
• Invitations in brochures and mission language must stress the availability to all of
recreation programs.
• The days of "we don't do the blind programs this week," have to be long gone.
Segregated programming is more expensive to develop, gets less use, separates
families at the door (e.g., dad is deaf so he gets a tour separate from the rest of
the family), and requires more staff-intensive work (development, training, and
scheduling). Most importantly, integrated programming acknowledges that all
people -- have varied learning styles, different levels of understanding and
experience in different subject areas, and usually come to recreation programs
with family and friends who are at different levels or may have different disabilities
than they do. Integration is both the most educationally sound and cost-effective
approach to programming.
• Life is rarely either agree or disagree. The survey is forcing answers - what about a
range from strongly agree to strongly disagree? Generally integrated programs
are best however I've seen instances where people with disabilities have
requested separate programs, for example a time slot in the pool/shower/locker
rooms that's just for women with disabilities. A hike and nature interpretation that's
for people who are blind.
• An agency should have policy not to duplicate programs for the sake of
accessibility. Emphasis should be on making programs and experiences available
to the widest possible audience without creating separate, duplicative programs.
most individuals with disabilities visiting a museum; recreation program, etc. do so
with their non-disabled companions, family, friends, etc. The social aspects of
recreation can't be ignored and thus the disabled individual wants, like everyone
else, to do things with their friends. At the same time, this may mean that they
won't get quite the in depth or intense experience they might be able to access
in a targeted crafted tour such as a "touch tour". Another example might be a
sports program - individuals with intellectual disabilities or certain kinds of physical
disabilities may feel shut out of an integrated sports program if they can't be
competitive, they also may loose out on the value of having peers around. The
key, of course, is to giving people the choice to participate in the type of
programming in which they are going to be the most comfortable and get the
maximum benefit. This is a choice best made by the individual and it may vary
depending on the type of activity/recreation being experienced.
• If all picnic areas are accessible, allows all users of recreational programs to use
whichever picnic area they want to
• Provide programs that offer participants with disabilities the option of being
included with all other registrants, such as with and exercise or fitness program.
• Designing an accessible playground where kids with and without disabilities can
play together.
No, I disagree %
3 17%
• There are a lot of "ifs" in your question. The best practice is always applicable
and desirable. If certain aspects of accessibility are not feasible, then it should
be the responsibility of the program to find a delivery that provides the consumer
with an experience as inclusive and integrated as is feasible.
11. A best practice in accessibility includes marketing materials and program brochures
that are accessibility-oriented for the promotion of inclusion of persons with disabilities.
Yes, I agree %
16 89%
• No example
• Marketing materials (brochures, for example) that contain photos of people with
and without disabilities playing together
• With the burgeoning baby boomer population, using larger, legible type; high-
contrast color combinations; glare-free paper; and larger, sharp images helps
any marketing and program materials reach and serve millions more in the
audience.
• There are two issues here: Program information, materials, and brochures should
be created in alternative formats, i.e., large print, Braille, CD. In addition,
program brochures, site materials, and websites should include information on
the accessibility of programs featured.
• All marketing materials should available in alternate formats and websites should
be accessible
• Having a TTY number on a document doesn't just say we promote inclusion but
demonstrates it
No, I disagree %
2 11%
12. A best practice in accessibility includes the goal that recreation and leisure
programs are accessible for persons with disabilities, unless an undue burden is imposed
on the agency.
Yes, I agree %
11 61%
• Budgeting is probably the best way to achieve this goal. Also targeted
fundraising. For example to request funds for sign language interpreters for a
program and provide credit for the fund givers.
• (If accessibility is included in the initial planning and design, few efforts to make
programs accessible would result in an undue burden to the agency.)
1. Persons with disabilities should be consulted in the planning and design of
programs.
2. When looking at existing programs, efforts to make them accessible should
start at the highest level of access, with alternative solutions considered if
enough resources are not available for full accessibility or there is an undue
burden on the agency.
• I support the notion of undue burden when talking about pre-ADA programs and
facilities, and when the financial burden would be high for a small operation that
provides highly specialized programs. Even then the bar should be set high to for
allowing an undue burden reason for noncompliance. New programs should
have a more difficult burden of proof, and only then after they consult with
accessibility experts in their field.
• All citizens have the right to recreate. Full inclusion is the only way to ensure that
each citizen has the opportunity to interact with those that may be different then
themselves.
• Undue Burden should be narrowly defined by most entities. Public entities have
a very high burden to provide accessible programs/services and a very narrow
exception would ever be at play. Seventeen years after the implementation of
the ADA it is very difficult to support any claim of undue burden (financial). There
may still be issues that would create a fundamental alternation in the program
and service but even those are rare anymore, especially if creativity is
incorporated into addressing a potential barrier.
Identify what options are available for providing the program/activity that would
eliminate or significantly reduce the barrier
No, I disagree %
7 39%
• I don't think a best practice goal should include undue burden considerations.
• Obviously a goal that recreation and leisure programs are accessible is a best
practice. However I have issues with the "unless an undue burden is imposed on
the agency". Too often agencies use this excuse to avoid making programs
accessible. Undue burden needs to be an extreme case that requires detailed
justification. If there is an undue burden, an alternative should be developed to
still meet the goal.
• Same as above...this is required! If the public entity can demonstrate that the
modifications would fundamentally alter the nature of its service, program, or
activity, it is not required to make the modification. The determination that
undue burdens would result must be based on all resources available for use in
the program. If an action would result in such an alteration or such burdens, the
public entity must take any other action that would not result in such an
National Center on Accessibility Appendix B - 21
alteration or such burdens but would nevertheless ensure that individuals with
disabilities receive the benefits and services of the program or activity.
• Perhaps the statement worked for existing programs that had to become
accessible years ago, but today new programs and services should be planned
with accessibility incorporated into the program, not included as an afterthought
to the design of the program. Yes, the law gives us the relief under undue
burden for extraordinary requests of a program, but our GOAL should be
inclusive accessibility.
13. A best practice in accessibility includes the goal that the majority of the facility
(building) is accessible for persons with disabilities, unless an undue burden is imposed
on the agency.
Yes, I agree %
10 56%
• State of Hawaii Department of Land and Natural Resources Transition Plan for
providing access.
• Just no question at all to this one. PWD should be able to enter the FRONT DOOR
and move about the same as anyone else. Period. The only exceptions (to me)
are historical buildings/sites, or those whose geography/topography just won't
permit it.
• Making certain that all programs within a facility are architecturally accessible
• More budgeting. Again, specific, targeted fundraising. Ask for money to make
the pond accessible. Grants, targeted donations.
• With new construction, all areas open to the public should be accessible unless
there is a clear burden imposed, such a small, multi-story building and the
elevator would be too costly. In this case, no programming should be planned
for the upper level that is not otherwise available to people with disabilities unless
there is a very good reason. Consideration also has to be given to the
employment of people with disabilities, which means areas for employees only
should also be accessible.
• Providing ramps, good signage, enough well marked parking. color contrast,
pictograms as well as words
• 17 years after the implementation of the ADA and over 30 years since
implementation of Section 504 of the Rehabilitation Act of 1973 leads me to
support the notion that no portion of a facility should be inaccessible to people
with disabilities at this point in time. If there are facilities that remain inaccessible
then they should no longer host programming that is open to the public or an
National Center on Accessibility Appendix B - 23
alternative location should be identified to facilitate inclusion of individuals with
disabilities who cannot access the inaccessible area of the facility.
Identify resources for removing the barrier, if none, relocate the activity to an
accessible location.
If resources are identified but the barrier cannot be removed immediately then a
temporary option for relocating the activity should be established and
implemented until the barrier can be removed.
Seek input from the public using the facilities and who have a stake in the
accessibility of the facility to get their feedback regarding prioritization of any
plans/use of resources needed to achieve accessibility of the program
No, I disagree %
8 44%
• Again, a best practice goal wouldn't include the undue burden consideration.
• All parts of the facility that are part of the programs should be accessible. If
meeting that goal produces an undue burden (needs to be an extreme case
that requires detailed justification), then an alternative should be developed to
still meet the goal.
• You can't lump all facilities together. The standards have been required since
1992!
• Again, this is not a best practice it is a legal defense position. The best practice
position would be to have a goal that all facilities will be made accessible to
persons with disabilities to the maximum extent feasible at any given time -- i.e.
as resources and circumstances change accessibility will always be a priority in
improvements, alterations, additions, etc to the built facilities and environments.
If you can't build that ramp today, it merely means that you will look at building
the ramp tomorrow -- not that you simply will never build a ramp.
• All buildings where programs are being offered must be accessible, or the
program shouldn't be in that building.
14. A best practice in accessibility fosters an organizational culture and attitude where
recreation staff recognizes and promotes the rights of all persons to access fulfilling and
enjoyable recreation activities, regardless of ability or disability.
Yes, I agree %
15 83%
• Yes, again, this is just a must. Staff attitude is everything. Negative staff attitude
can ruin the 'most accessible' facility and experience. Staff should ASK
individuals IF and HOW help should be given...and then LISTEN to that!
• Staff and administrators speak of good customer service across the agency
• The agency has a mission, goals, and objectives that promote inclusiveness in all
programs, practices, and policies.
• Participation in events like CAST-For-Kids helps staff see that persons with
disabilities want to and enjoy activities that they may otherwise not be able to
participate in and should encourage the staff to promote this on an everyday
basis, not just on special days
• Organization core values should indicate a philosophy that all people in the
community, including persons with disabilities have a right to access and
participate in recreation services and have the ability to benefit from them in the
same way as people without disabilities.
• To achieve such an organizational culture and attitude, you need to have many
of the things discussed earlier in the survey in place, i.e., policy, training, facility
and program access, etc.
• An organizational mission which includes the inclusion of all and encourages the
practice.
• City of Rockford, IL has inclusive programming where the
management/organization has worked to ensure that all staff are aware of
disability related issues and that all programming involves people with/without
disabilities. They have worked to eliminate the "special" title in their programming
so that individuals can easily access any programs available and adaptations
can be made within an inclusive setting. The staff within this agency have
worked hard to bring this about and continue to do so in order to maintain the
programming philosophy. It think that this is a struggle when management, staff
change because it is not always institutionalized to approach these issues in the
same way from one administration to another. It is important that programming
policies/procedures are establish to institutionalize these issues so that it is not
dependent upon the individuals in the position but that the organizational
culture is such that no matter who works in any position there remains an
understanding that this is how things are done at that facility or within that entity.
Disability is no longer the add on or "special" consideration and that needs
associated with inclusion of people with disabilities are addressed from the
development of any program and that budgeting, etc. is inclusive of the costs
that may be associated with accommodations, etc. instead of looking for the
money after the program is planned and it is determined that it may cost more
to accommodate.
No, I disagree %
3 17%
• At face value, this is minimum standard, not a best practice. It could become a
best practice, depending on what that culture and attitude promotes.
15. A best practice in accessibility includes practices to reasonably accommodate
persons with disabilities in recreation and leisure activities through the provision of
adaptive equipment and program modifications.
Yes, I agree %
14 78%
• City and County of Honolulu provision of beach chairs. City and County of
Honolulu golf course provision of carts for persons with disabilities and
modification of policy to allow people with disabilities to use a cart to ride on the
course.
• Sit-down/Stand-up tennis
• This is all a part of having good policies and procedures in place to make
accommodations as needed or requested.
• A program that provides bicycles for rent should have hand cycles available as
well. A bowling alley should provide ball ramps and have retracting handle balls
available. Theaters should have equipment available to enhance sound for
individuals with hearing impairments.
• accessible trails and descriptors of suitability, provision of an interpreter when
needed, providing a buddy to assist in the activity
• Availability of sit ski's and other adaptive equipment at ski resorts for rent/lease
the same as someone is able to rent standard ski equipment. Some of the ski
resorts in Colorado have this option available. Very few in the mid-west that I am
aware of (Duluth City Ski Hill (Can't recall the name), Granite Peak (Wausau) that
I am aware of. Duluth also has ski instruction available for people with disabilities
similar to what they have available for individuals without disability which
encourages someone who may not have tried it before to venture out and
enables families with individuals with disabilities to participate equally in the
activity without having the family member with the disability having to go
somewhere else to learn, etc. Everything can be done collaboratively/inclusively
with friends, family, etc. Specialized staff are available but they also work with
the resort staff to make them more comfortable with the issues/equipment, etc.
so that they are able to problem-solve when specialized staff are not available.
Does not limit someone from using the equipment/services to only when
"specialized staff" are available.
No, I disagree %
4 22%
• Required!
16. Please identify any additional best practices that should be included.
• Recruiting staff and volunteers with disabilities to develop and deliver public
programs brings the organization's commitment to access to a higher level and
obliterates the "us doing for them" appearances.
Also integrating (as appropriate) information about people with disabilities into
the content of exhibitions, tours, public programs lets all of the public know
about the roles and contributions of people with disabilities in American, state,
and local history as well as in parks and recreation in general.
• You are doing a disservice to any park and recreation agency to lead them to
believe that their requirements under the ADA are simply "best practices".
APPENDIX C
Part 1 of 2: In Round One, consensus was not reached on three best practices in
accessibility.
1. A best practice in accessibility includes the goal that recreation and leisure
programs are accessible for persons with disabilities, unless an undue burden is
imposed on the agency.
Yes, I agree %
2 14%
No, I disagree %
12 86%
• An undue burden for one agency may not be an undue burden for another. A
best practice, I believe, is an example of an efficient method to provide
accessibility. Other agency's may or may not use it as they see fit. Thus, undue
burden considerations should not be a factor.
• Undue burden is an exception, primarily for existing conditions. Best practice
should not address exceptions
• I continue to agree with those who disagreed. This statement indicates basic
compliance with the minimum requirements of the law, not best practice. While
even best practice should not create an undue burden on an organization, a
best practice should produce OPTIMAL accessibility -- through the best means
possible -- for the audience of people with disabilities.
• "Undue burden" merely provides agencies with an "out" and prompts many
agencies to figure out ways to avoid being accessible to all. Would not include
this component in a best practice statement.
• This is a legal standard per the requirements of the ADA and not a best practice.
Would be the same as saying a 'best practice' is to follow FLSA or OSHA
standards.
• I agree with respondents that this is a legal/minimum standard but at the same
time recognize that there is a very high burden of proof that something is an
undue burden so that using this defense should be the "exception" rather than
the rule. Entities have used this excuse not to create access because of a lack
of consequence for not being accessible. The enforcement system is flawed
and has allowed many entities to avoid compliance for a lack of effective
enforcement. Not because they are in compliance or can defend an "undue
burden" claim. Removing the statement "unless an undue burden is imposed on
the agency" would better articulate the "best practice" of full inclusion and
access for everyone.
• For all the reasons listed below. When a public entity offers a special program for
individuals with a particular disability, but an individual with that disability elects
to participate in the regular program rather than in the separate program, the
public entity may still have obligations to provide an opportunity for that
individual to benefit from the regular program. The fact that a separate program
is offered may be a factor in determining the extent of the obligations under the
regular program, but only if the separate program is appropriate to the needs of
the particular individual with a disability.
• The ADA requires that government agencies provide program access, but
private entities are not required under the ADA to provide services unless it would
create an undue burden. This standard should not be considered a best
practice. Best practice can go beyond what the current law requires to a
standard of full accessibility. Entities should be encouraged to consider the ADA
and other accessibility laws as a baseline for compliance, not the maximum
effort an entity should be encouraged to provide.
• The goal is full inclusion and integration of people with disabilities. Leave the
budgeting and financial considerations to the managers to figure out. Undue
burden is specifically a legal term and is not needed in a best practice
statement.
2. A best practice in accessibility includes the goal that the majority of the facility
(building) is accessible for persons with disabilities, unless an undue burden is
imposed on the agency.
Yes, I agree %
2 14%
• Areas of the facility necessary for the program and all of its support components
(at a minimum) should be accessible. This is certainly true for a post 1992 facility.
The term "majority" has little meaning when considering what should be or needs
to be accessible. Areas of no consequence to the services being provided are
generally of no concern to the participant with a disability. I don't see how this
would be different when thinking in terms of best practice.
• The best practice comes into play here when you are looking at all of the
programs offered by the entity are accessible. Not every facility may be
accessible for a variety of reasons given the sheer magnitude of facilities out
there. If an entity can ensure that all of its programs are accessible through
relocation, etc. then they have achieved the best practice of having all of their
programs/services accessible. Looking only at the physical structure sells many
entities short on whether or not they have achieved best practice. New
construction definitely but I have seen even new construction that meets the
"letter of accessibility" but the programs remain inaccessible due to
policy/procedural issues, etc.
No, I disagree %
12 86%
• Once again, I have changed my answer with the same reasoning at the
previous question. A higher level of access should be expected as a "best
practice," without regard to burden. Better planning and creative thought
would in most cases, I believe, negate a possible undue burden.
• An undue burden for one agency may not be an undue burden for another. A
best practice, I believe, is an example of an efficient method to provide
accessibility. Other agency's may or may not use it as they see fit. Thus, undue
burden considerations should not be a factor.
• I continue to disagree. I think the term "majority of the facility" is too broad a
term to be useful; the statement doesn't account for new construction vs.
existing building vs. historic site; and it still reads as a minimum requirement. I
think these details would have to be spelled out, the ante raised above the
National Center on Accessibility Appendix C - 4
minimums, and the interaction of the building and the accessible programs (e.g.,
the ease of use by people with disabilities of the space and its amenities) will
have to be explained to fall within the realm of best practice.
• This question still confuses "best practice" with "legal practice". A best practice
doesn't include an "exception because of undue burden". The ultimate goal is all
facilities being made accessible not just the majority. Can't say I've done 80%
and now I can stop, must strive for 100%.
• The best practice should state that the facility is architecturally accessible. At
the least, a program originally designed for an inaccessible location must be
relocated to an accessible one.
• I am persuaded by the arguments here and would delete the "undue burden"
clause here.
• The best practice and goal (it's sort of redundant, either it's a best practice or it's
a goal, simplify language) is to make all facilities fully accessible. In the process
of doing that make sure the programs, services and activities are fully accessible.
Leave financial considerations to management. As previously stated undue
burden is a legal term, not needed in a best practice statement.
• The word majority is giving me pause; it is so hard to align this with current new
building requirements. Best practice can again exceed the current legal
requirement and as a best practice I would want to say something more
affirmative such as all programmatic areas are accessible for people with
disabilities.
• As previously stated...you cannot view all facilities the same. This assumption
could find a professional on the wrong side of compliance.
• The word majority is giving me pause; it is so hard to align this with current new
building requirements. Best practice can again exceed the current legal
requirement and as a best practice I would want to say something more
affirmative such as all programmatic areas are accessible for people with
disabilities.
• The best practice and goal (it's sort of redundant, either it's a best practice or it's
a goal, simplify language) is to make all facilities fully accessible. In the process
of doing that make sure the programs, services and activities are fully accessible.
Leave financial considerations to management. As previously stated undue
burden is a legal term, not needed in a best practice statement.
3. A best practice in accessibility includes practices to reasonably accommodate
persons with disabilities in recreation and leisure activities through the provision of
adaptive equipment and program modifications.
Yes, I agree %
7 50%
• OK, I believe before I was one who said this is a minimum standard. But I'll also
say it is a best practice since this statement has no undue burden clause.
• a softball field that has a firm and stable surface, accessible dugouts, bases
outlined on the field, no abrupt changes in level
• A best practice, I believe includes such general provisions. But the specific
practices such as the provision of automatic door openers or providing a greater
staff to camper ratio when participants have a disability are necessary to define
the best practice.
• Best practice does not necessarily mean going beyond what is required or
expected, unless it would substantially raise the quality of or access to, etc. the
experience. When the participant with a disability is afforded all the same
opportunities as other patrons then this could be considered best practice. There
are too many examples of recreation agencies/programs not meeting an
expected accessibility minimum. When an agency achieves the equal
access/equal opportunities threshold, it puts them in the higher percentile.
• I stick by my first answer and agree to this statement, although I don't like using
the term "reasonable accommodation" which is in actuality an employment
term. Using adaptive equipment and program modifications, without changing
the fundamental nature of the activity, to include the greatest number of
participants, including those with disabilities, would be a best practice in my
mind.
No, I disagree %
7 50%
• "Reasonable accommodation" is a legal term in Title I (employment) of the ADA
and the Fair Housing Act, the term does not apply in this context and is
confusing. The best practice is inclusion and integration of people with disabilities
however that needs to occur. The minimum requirement is providing auxiliary
aids and services (unless undue burden) and reasonable modifications of
policies, practices and procedures.
• This still reads as a minimum, and, I agree with one of the respondents who
disagreed, the term "reasonably accommodate" confuses the issue. While
"reasonableness" doesn't have to be discounted even in best practices, the
emphasis should be on the level of accessibility the adaptive equipment and
program modifications provide. You can spend a small fortune on equipment
and still not provide best-practice (or minimum requirement) access.
Part 2 of 2: In Round One, respondents were asked to provide additional examples of
best practices. The following questions reflect the examples given by the panel of
experts.
Yes, I agree %
9 64%
• Sometimes, we see shiny new things or cool technologies, and we invest a lot of
resources in them only to find out they don't work. Appropriate background
research, market testing, including a measured approach will avoid costly
mistakes.
• The change in ADAABAAG that did not differentiate between side and front
reach was based on the needs of people with disabilities.
• This would be true of any recreation program. Too many programs make
decisions without the evidence to support them.
• This sentence can be read and interpreted a couple of different ways. First of all,
if "needs" of people with disabilities equates with "desires," the needs would be
the same as those of people without disabilities. However, "needs" interpreted as
what is necessary to make an accommodation or adaptation for an activity
would be different. In that case, I would agree with this statement. An example
might be adapting a fitness program and equipment to accommodate a
person with a disability. To ensure a "best practice" and success, it would be
advisable to base those adaptations on research of equipment and program
outcomes
No, I disagree %
5 36%
• Again, the term accommodation is confusing here since it has legal meaning
elsewhere. I know what research is, and I think providing adaptations that are
National Center on Accessibility Appendix C - 8
research based is a good idea, but I don't know what the phase "program
outcomes about the needs of people with disabilities" means.
• I know what research is and I know what program outcomes are but I am
uncertain how they apply to best practices in this context.
• Best practice should incorporate input from people with disabilities about their
needs and what works/does not work for them. Establishing "outcomes" can only
be done when people with disabilities are consulted regarding what the best
outcomes for them may be. This will differ by populations and may differ within
the same populations based on age, ethnicity, etc. in additional to disability
status. I don't necessarily agree that determining what accommodations are
needed necessitates a research project. Involving people with disabilities in the
development, planning, etc. provides rich data for establishing programming
needs and what accommodations are needed to ensure that everyone can
participate. Research with a little "r" versus big "R" may be relevant to identify
those entities that have engaged in programs/activities that meet the needs of
various groups would be valuable information for any program to have and
something that they should already be doing.
• Again, the term accommodation is confusing here since it has legal meaning
elsewhere. I know what research is, and I think providing adaptations that are
research based is a good idea, but I don't know what the phase "program
outcomes about the needs of people with disabilities" means.
2. A best practice in accessibility includes phasing out adaptations when appropriate.
Yes, I agree %
9 64%
• If adaptations are being provided, they should have been implemented based
on findings from an assessment or the expressed input from the participant or
his/her care provider. Continuing the adaptation should be based on similar
evaluative information. If the program is intended to develop skill or ability, then it
would probably be a goal to phase out or lessen the use of adaptations.
• Adaptations needed can be minimized when the barriers in the environment are
removed. This includes making sure that all instructional information (i.e. video's,
manuals, etc.) are accessible from the initial design versus requiring a request for
accommodation on a case by case basis. Having automatic doors,
alarms/systems, information kiosks, etc. that are multi-modal (not solely reliant
upon vision, speech or physical ability to operate or access) creates an
environment that everyone can access and does not require special
accommodation on case by case basis.
No, I disagree %
5 36%
• A qualified disability is usually permanent. I don't see phasing out adaptations
for access as an option.
• I'm not sure how to interpret this question - it is ambiguous. What does it mean
"when appropriate"? Does that mean with a certain percentage of people
don't need it anymore? Or does it mean when no-one needs it anymore? A
better statement is “A best practice in accessibility involves evaluating and re-
assessing adaptations for effectiveness."
3. A best practice in accessibility includes full survey of facilities, programs,
communication plans, and outreach on at least a five year basis.
Yes, I agree %
6 43%
• Good one. The Title II requirements don't include this so it is something that
exceeds the minimum requirements.
• Things change over time, such as caused by erosion or new devices for effective
communication. Re-evaluation is a must.
No, I disagree %
8 57%
• A full initial facility and programmatic survey would be a best practice for any
program. Additionally, those surveys must be updated at the very least
periodically and whenever new programs, facilities, etc. are added. I disagree
on the time frame. I think a review at least every three years, maybe not a full
accessibility survey, should be done.
• I think five years is too long between evaluations/surveys. I think there should be
ongoing evaluation of some accessibility related components, such as available
communication technology, adapted equipment or identifying changes in the
community constituencies.
does it have to be a "full survey"? Does it have to happen on a five year basis?
All of that would depend on the specific situation and circumstances.
• The time frame may not be appropriate for all agencies and/or programs. It
should be based on the needs of the agency, work completed, changes in
policies, etc.
4. A best practice in accessibility includes one person designated to have the
authority to provide, modify, and assist staff in provision of services and receive
complaints.
Yes, I agree %
7 50%
• In an ideal world, it would be nice if everyone on staff takes full responsibility for
accessibility. But in reality, training all staff is best, when they know that there is
one person to whom they can turn who has the expertise, knowledge and
experience in the field of accessibility and who has the ultimate authority to
make a decision regarding the provision of services and accommodations.
Additionally, complaints really do have to be handled by one (or two or three -
but specifically designated individual(s)) person who is specifically trained to
deal with complaints and who has the authority and resources to resolve the
issues.
• Having one person as the point of contact not only shows the public that the
owner takes this issue seriously (who is in charge here), but also helps staff know
who to go to if there are problems. Most other services provide a point of
contact
• An "expert" with authority. (i.e. to evaluate new facilities, training, part of job to
keep up with new requirements for access)
• Without one individual there is usually confusion from the public, an unfocused
response and concern and lack of attention. There can be a whole team of
Specialists but with one single "leader" who is the contact person. This individual
should also have the authority to make basic decisions and to oversee the
service provision and complaint process.
• Without one individual there is usually confusion from the public, an unfocused
response and concern and lack of attention. There can be a whole team of
Specialists but with one single "leader" who is the contact person. This individual
should also have the authority to make basic decisions and to oversee the
service provision and complaint process.
No, I disagree %
7 50%
• I don't think one person should have the sole authority. I think staff should be
empowered to provide or modify services to enhance accessibility through
creative planning and consultation with participants and other staff members.
• Again, I may be arguing wording more than intent. I think a best practice
includes a permanent position or at least part of a position with "the authority to
provide modify, and assist. . . “That position must be filled by a qualified
individual who has experience and understanding about providing access. We
all know about the 504 coordinator who is really an accountant and has this
assigned as a collateral duty (and knows nothing about it); or the dedicated
person who develops a grassroots program, leaves the organization, and has no
one remaining in the organization to take up the carefully built program. This
position must also have the full support of senior management to be successful.
• I don't necessarily believe that having all power/responsibility resting with one
person is necessarily best practice. In large systems it may not be realistic to
have only one person in this role. There may need to be someone identified with
authority within different aspects of programs/facilities (i.e. Outdoor facilities,
water related facilities, classes/courses, etc.) in order to assure that the workload
is realistic and that adequate expertise in these areas is available. Someone with
facility expertise may not necessarily be expert in program access and I don't
believe it's realistic to expect that as a best practice. Overloading someone so
that they can't respond to anything in a timely manner is not best practice.
Infusing the expertise across many aspects of the management of a program is
likely to have more systemic affect. The size of an entity may make the
difference here more than anything.
National Center on Accessibility Appendix C - 15
5. A best practice in accessibility includes recruiting staff and volunteers with
disabilities to develop and deliver public programs.
Yes, I agree %
13 93%
• Yes. Just as women in parks and recreation are effective in serving female
customers, so will be recreation specialists with disabilities.
• I think this is a form of affirmative action for persons with disabilities, and have
no problem with it. Based on my experience, a qualified person with a
disability in a position of program planning and delivery has numerous
positive benefits that might not otherwise be achieved without him/her.
• As with other minority groups sensitivity and "walking the walk" is very
important with the disability community as well.
• Yes, people with disabilities will have the personal experience and may help
others with disabilities to feel more comfortable participating.
• Staff/volunteers in any program should reflect those that are served by that
program and serve to mentor/teach, etc. where applicable. This is a
universal best practice across all aspects of age, disability, cultural
differences, etc. Including people with disabilities in the mix of
National Center on Accessibility Appendix C - 16
staff/volunteers is logical. More important is having "qualified" individuals
within these positions which also includes having programs that pro actively
develop opportunities for people with disabilities (kids, youth, and older
adults) to have opportunities to be volunteers and that may eventually lead
to paid staff positions. Many volunteer programs do not adequately
accommodate/recruit people with disabilities because they don't know how
to accommodate them.
• As with other minority groups sensitivity and "walking the walk" is very
important with the disability community as well.
No, I disagree %
1 7%
6. A best practice in accessibility includes integrating (as appropriate) information
about people with disabilities into the content of exhibitions, tours, and public
programs.
Yes, I agree %
11 79%
• People connect with things that are reflective of their own experiences or
which they can identify with in someway or another. We like to see ourselves,
people like us, in programs, exhibitions, performances, films, etc.
• The dispute over the FDR memorial in DC -- whether the memorial should
show FDR's disability -- made clear how important it is to include information
about people with disabilities, as appropriate, but also in appropriate ways.
• Program information used for marketing and public relations often depicts a
desired outcome or situation. If you want to be an inclusive program then it
would be reasonable to indicate this in your materials.
• Yes, definitely again. For instance, the tours and exhibitions at Ellis Island
would not be accurate if they did not include the story of how immigrants
with disabilities were "weeded out" and denied entry into the U.S. The same
goes for the Holocaust and the numbers of people with disabilities who were
singled out and murdered, tortured, and used in experiments based solely on
the presence of their disability. The "story of disability" is often a key part in
many presentations.
• Again universal design and provision of information that can be useful not
only to those who consider themselves to be a member of “those with
disabilities", but also an individual who maybe older or who considers
themselves just to be unable to walk, talk, move a certain way, etc., but not
severely enough to be considered in their mind to be disabled.
No, I disagree %
3 21%
• Can't answer this because I don't know what "information about people with
disabilities" means in the context of a recreation program's exhibitions, tours and
public programs.
• How does providing information about people with disabilities into the content of
exhibitions or tours make them more accessible? It may promote a positive
attitude but does not really address accessibility.
7. A best practice in accessibility includes expenditures related to the purchase of
adapted equipment, services, and/or accessibility improvement projects in the
financial planning and budgeting process.
Yes, I agree %
14 100%
• Any program should examine all associated costs and determine what they are
and how they will be paid for. This includes understanding how costs that may
not be consistent (i.e. sign language interpreters) play into planning or classes,
etc. and if the entity is charging for services how these costs would be built into
the overall fees associated with the program. Capital costs associated with new
construction that may include some elements required to ensure accessibility
should be reflected in the overall costs of the project and anything attributed to
accessibility should not be identified as a separate cost. Long term planning
should include costs associated with making necessary modifications to existing
facilities that improve accessibility. Best practice would be to establish a long
term plan with associated costs related to achieving full accessibility in all
facilities, even if a program can be relocated, etc. The eventual goal should be
to achieve full accessibility in all facilities over time while maintaining program
accessibility through alternative methods until the facilities can become fully
accessible.
• Funding specifically budgeted (line item) for access related devices, facility
rehab, etc. establishes a priority and hopefully ensures that money will be spent
on needed access.
• Not sure if this is a "best practice in accessibility". The planning and budgeting
process should ensure that expenditures for all issues - accessibility, safety, life
safety - are accounted for in the process. If you need an accessible picnic table,
then an accessible picnic table needs to be purchased.
• No brainer. Best practice or not, access starts with budgeting and anticipating
expenses.
8. A best practice in accessibility includes public programming that reflects the
diversity of communities to include people with disabilities.
Yes, I agree %
11 79%
• This seems obvious, that people with disabilities are a part of all communities.
• Individuals with disabilities have interests and skills as varied as anyone else.
(i.e. sports, classes, travel, etc.)
• People with disabilities are part of the community, not a separate feature of
one. Accessibility should be included in public programming as a matter of
course, not an additional thought, to insure participation by community
members with disabilities.
No, I disagree %
3 21%
9. A best practice in accessibility includes a policy to exceed minimum scope of
requirements.
Yes, I agree %
10 71%
• Must go well beyond the laws which are merely minimal standards.
• To quote Ray Bloomer, "Minimum requirements are the WORST you can do."
By definition, BEST practices exceed that. A 1:12 ramp is the minimum; a 1:16
ramp better serves more people and is, therefore, better practice. A policy
makes that happen consistently.
• Minimum scope does not provide for everyone with a disability. The policy
should indicate that the needs of every person with a disability will be met in
order for them to participate if that is possible within reasonable resource and
safety considerations. The intent of the policy should be understood that it will
be interpreted whenever possible to create access for individuals.
• Minimum scoping such as the ADA should always be considered the baseline
or minimum, not the maximum that should be done! A policy that expects a
greater level of accessibility challenges those responsible for services to
evaluate how to better provide services and not just meet the stated
minimum.
• Incorporating policy and practice that looks beyond the legal requirements is
essential to a best practice in accessibility. Doing more than required in
facility access means that you look beyond 1 stall in the toilet room that is
accessible and that the ramps are usable, not just minimally accessible (1:12
slope) and that sign language interpreters are scheduled for all activities and
only canceled when someone does not request them, not visa versa when
entities scramble to find an interpreter when it's requested and often can't
because of timing, etc. Being proactive versus solely reactive is a measure of
best practice in accessibility. Build it and they shall come versus build it when
they do come.
• Must go well beyond the laws which are merely minimal standards.
No, I disagree %
4 29%
• Would agree with this statement if the phrase "wherever possible" was added.
While a goal to exceed minimum scoping should be considered in any
design or development of facilities or programs, to require an owner by policy
to exceed requirements may not be doable due to site conditions, funding
issues, or program goals.
APPENDIX D
In Round Two, eight questions were asked where the expert panel did not reach
consensus.
Yes, I agree %
6 50%
• I still agree. I wonder if those who disagree don't believe a program could be a
"best practice" if it included accommodations through adaptive equipment and
program modifications? Or do they think that provision of such would just be a
"minimal" practice?" I disagree with both opinions. I've seen "best practices"
defined as practices that the provision of assistive listening devices, accessible
playground equipment with a variety of elements, 508 accessible computers.
variety of programs/service available to enable someone to learn how to use
the equipment if they are not familiar with it already and to not have to
purchase their own equipment (i.e. having a variety of sit ski's or other type of ski
equipment available at a ski hill for someone to use) even though from a legal
standpoint it could be argued that providing specialized equipment was not
necessarily legally required but modifying the policy to allow someone to take
their own sit ski on the ski lift would be required. The range of equipment that
would be needed to accommodate a wide variety of users in recreational
settings is extensive and best practice would be having that range available as
that would demonstrate going beyond the minimum of the law.
No, I disagree %
6 50%
• Modifying programs and providing adaptive equipment are minimums. How you
do it and with what may be best practices.
• The statement is too limiting and confusing. How about...The use of adaptive
equipment and other program modification are possible ways to accommodate
persons with disabilities in recreation and leisure activities.
• This question asks for "best practices" through the provision of adaptive
equipment and program modifications.....normally I would say "best practices"
go above and beyond what is expected or required but as it relates to program
modification.....I would expect the best modification to be considered when
including a person. "Best practices" might be more easily recognized in the
example of a playground. There is a minimal level required for accessibility but
there are many more implements that can be added to increase the level of
accessibility.
2. A best practice in accessibility includes accommodations based on research and
program outcomes about the needs of people with disabilities.
Yes, I agree %
7 58%
• The provision of "modifications", which meets the need of the various degrees of
disability. For example, individuals, who are hard of hearing are not deaf and
must be able to use what hearing they do have in the program setting.
Therefore we should have available at least three types of "modifications"-
Assistive listening devices, captioning, and sign language interpreters.
• If you do not include the individuals into the decisions of how to solve issues and
ASSUME what works best you often are wrong. Proper research includes
samplings of a wide range of individuals, their specific "modifications" and its
success. To sell products you do market research. If your research was sound the
product is more likely to sell. if you have no, or poor research, i.e. ask the wrong
questions you will get the wrong answers and the likelihood of failure increases
dramatically
• Research can inform policy makers and assist in making an argument "why"
something is needed, especially if that research is participatory action research
where the individual is included in determining the problem(s) and shaping the
process for determining the outcomes. For example, examining how people
who use electric scooters experience various features (i.e. lifts on buses, turning
radius in bathrooms, etc.) leads to information that informs those involved with
establishing relevant standards/guidelines. People with disabilities should be
central to any decisions about them and thus, any programs that may be
considered should incorporate feedback from people with disabilities (program
design, implementation as well as evaluation of effectiveness once
implemented).
No, I disagree %
5 42%
• After reading what other respondents wrote, I disagree with the statement as
written because it implies that people with disabilities themselves are not
consulted about what accommodations might be best for them. I agree that
decisions on accommodations based on research and "perceived" outcomes
are also vitally important, but the statement should, as pointed out by others,
include input by program participants (people with disabilities) themselves. Initial
program planning could be done based on research and perceived outcomes,
but must leave room for "tweaking" based on individual needs.
• I still feel that this one smacks of "we'll decide what to do for them," which doesn't
say "best practice" to me. I'll stay with the following: A best practice includes
program and facility DESIGN (with the accommodations seamlessly included)
based on input of people with disabilities, research, and program outcomes.
• As stated I don't think this gives much direction. Should you research ways to
accommodate the needs of people with disabilities...yes! Should you have
program outcomes....yes! But shouldn't you have "program outcomes"
regardless?
• I think that utilizing the experiences of people with disabilities is a must in addition
to research and identifying program outcomes.
3. A best practice in accessibility includes phasing out adaptations when appropriate.
Yes, I agree %
8 67%
• When appropriate surely seems to mean when it is in the best interest of the
participant with a disability (other considerations aside). Through specific
observations and other evaluations, a service provider should be able to
determine when an adaptation is still serving a needed purpose and when it is or
has become a barrier to progress or just not needed anymore.
• I interpret this question to mean that adaptations are often needed because a
barrier exists within a certain environment or program. Adaptations are at the
individual level but can also be applied at a macro level. For example,
temporary adaptations may be made in environments that are not currently
accessible but once renovation is done to a site/facility then the adaptation
may no longer be needed (i.e. beach mats may be used in areas where there
are no walkways that are accessible but when renovations are made to the
area the path of travel is developed that meets the Accessibility standards and
then the adaptation of the beach mats as an accessible surface is no longer
needed.
No, I disagree %
4 33%
• I agree with all the disagreement comments. I think this has to be re-done or
eliminated.
• The question is difficult to answer in its wording. Another respondent stated the
disagreement very well. "What does it mean ...a certain number of people do
not need it or percentage, it could also include no one is participating anymore,
there is new or better products or designs and the adaption is no longer needed
for anyone. i.e. electric sensor faucets vs. levers or knobs. or computer e mail
web registration for programs from home vs. driving to and inaccessible site to
be in line and unable to fill out a form because the counter is too high
• Don't agree or disagree. The "best practice" would need to define what is
considered an "adaptation" and a best practice on "when it is appropriate"
4. A best practice in accessibility includes full survey of facilities, programs,
communication plans, and outreach on at least a five year basis.
Yes, I agree %
5 42%
• We build or alter facilities on a continuing basis and often forget about required
directional signage to accessible elements. A regular survey of facilities should
identify these oversights. Also, a system of for survey of newly constructed
facilities must be established to ensure that contractors have met requirements
before we sign off as completed.
• Five years could be a good time frame for many. Other factors may require a
shorter time frame, new facilities, a significant change in the population, i.e. a
new sport or activity which has brought greater participation in individuals with
disabilities participating; Staff change overs with the program provider may
make revisiting the facility and reevaluating the program necessary.
Accountability of accessibility to buildings, structures, sites, programs etc all may
have different time frames. It may very well depend on the size and or budget of
a provider. Possibly linking it to the schedule for budget requests, and requiring
an accessibility accountability/update is a better way to track.
• I think the idea of a FULL survey as described is best practice and would be a big
undertaking, requiring a lot of knowledge about accessibility in all of these areas.
Attempting to do this more frequently than 5 years would be unrealistic. At the
same time, a mechanism should be in place that triggers a review when an
accessibility concern arises at any time.
No, I disagree %
7 58%
• If accessibility is incorporated into the on-going operations of the organization
and if accessibility is something ingrained in the organizations
structure/philosophy and operations then periodic review of "accessibility" such
as identified in this question should not be necessary. Best practice is when
accessibility is no longer "special" and that the issues that are typically singled out
as only related to accessibility become viewed as part of the overall operations
and are reviewed/assessed/etc. at the same time any other issues are
addressed. Removing this issue as a "special" consideration that requires a
separate structure to review it will mean that you have achieved best practice.
5. A best practice in accessibility includes one person designated to have the
authority to provide, modify, and assist staff in provision of services and receive
complaints.
Yes, I agree %
3 25%
• As long as there is a team that works with the designated person that has the
needed expertise in a variety of areas such as facilities. If there is no one person
that is assigned this task and to assure that accessibility is provided, then often,
even in the most well intentioned facilities, it can become overlooked or
underfunded.
• I think size is very important here. In a small agency, having one person in that
position of authority would be sufficient. In a large agency with multiple
operations and facilities, one person would probably not be sufficient. I also do
not support the approach of one person having absolute authority in this
position. More people need to be involved in the decision making process. I am
more comfortable with a coordinator that educates, facilitates, organizes, etc.
No, I disagree %
9 75%
• I still disagree that one sole person should have the authority to do all that this
statement suggests. (Here is where wording becomes misleading.) I believe all
staff should be empowered to "provide, modify, and assist staff in the provision of
services." But I would agree that at least one person on staff should have the
knowledge and authority to address complaints in a positive manner.
Additionally, while all staff should have knowledge of accessibility and disability
issues, at least one person should have additional expertise and knowledge, as
well as authority to make agency decisions, to serve as the point of contact and
resource person for issues or needs that may arise.
• The "one-person" rule may interfere with others throughout the agency coming
on board.
• This combines too many issues. Yes...one office place needs to be designated
for complaints. Other issues may benefit with a "coordination" role, but the
responsibility (as other respondents have explained) rests with everyone - the
landscape architect, program leader, or bus driver.
• Decision making should not rest with just one person. There should be an ADA
Coordinator for a program to help facilitate and resolve difficult questions but
not be the only one to make decisions.
6. A best practice in accessibility includes integrating (as appropriate) information
about people with disabilities into the content of exhibitions, tours, and public
programs.
Yes, I agree %
8 67%
• Persons with disabilities must be integrated into exhibits, tours, etc. The accurate
depiction is also important, WHY didn’t we see so many folks using wheelchairs in
the past, weren’t as many, they couldn’t get there! or get in, its all valid,
hopefully depicting individuals with disabilities into all programs, marketing will be
a standard very soon, and not just showing "super gimp” or oh poor pathetic we
feel bad for you image either
No, I disagree %
4 33%
• I don't know what this means. A best practice includes ensuring that people with
disabilities are represented equally as users in the content of exhibitions, tours,
etc. to show inclusiveness.
7. A best practice in accessibility includes public programming that reflects the
diversity of communities to include people with disabilities.
Yes, I agree %
11 92%
• People with disabilities are part of the diversity of our country and should be
reflected as such.
• Inclusive programs, buildings and sites is the point. Focusing only on wheelchair
access as an after thought or equipment for individuals as a way to
accommodate after the program exists is the backwards way of including
persons. Understanding the communities broad diversity , age, ethnic, religious,
and disability are all part of successful programs
• A narrow view of best practice would see accessibility isolated from other
practices. I think it is important to see and encourage the interrelated nature of
access with events that expand community awareness of its diversity.
Fundamentally we are talking about human differences and what communities
believe and do in regard to acceptance and inclusion. This potentially impacts
local decisions about resource allocation and other policies regarding
accessibility.
• I would like to think that all communities should/would serve their constituents but
the reality is that not all communities do address the needs of people with
disabilities. So, best practices are a community that offers programs. Hopefully
this will change with time.
looking for sports opportunities that allow them to maximize their skills/talents
within competitive and non-competitive arenas.
No, I disagree %
1 8%
8. A best practice in accessibility includes a policy to exceed minimum scope of
requirements.
Yes, I agree %
10 83%
• Still agree with this statement. I would concede to adding the wording
"whenever possible" to the end of the statement, although I think it would be
assumed.
• The provision of automatic doors, beach wheel chairs, and single rider golf-carts
are not believed to be required but should be.
• I too must quote Ray Bloomer, as I often do, minimum standards are the WORST
you can do the difficult part is to have a policy? I am not sure that it is the best
way to ensure achieving best practice yet I can not think of a better way.
• Often min requirements are seen as the maximum needed to do for accessibility.
• Assuming that practice follows policy, and an agency wants to create the most
accessible environment/services they can, then a policy that provided
guidelines for exceeding minimum standards would be necessary. In this way,
the policy would be rewriting the standards to establish a new minimum
expectation. Such a policy would need to be as specific as possible.
• Policy that supports use of universal design goes above the minimum standards
and should be what entities strive for. For example, a design that offers both a
stairway and a ramp as options to enter the building does not reflect universal
design. A policy that requires that any feature be able to be used by "everyone"
would support universal design and go beyond the minimum of legal
compliance.
No, I disagree %
2 17%
• "Best practices" always exceed minimum requirements. That is what makes them
exemplary.
• What is the minimum scope of requirements" This needs to be more specific. Are
you talking about "design" requirements? Program, etc.
APPENDIX E
In Round Three, six questions were asked where the expert panel did not reach
consensus.
Yes, I agree %
4 44%
• We can continue to argue semantics, but the intent is this: does best practice
INCLUDE the provision of adaptive equipment and program modifications. It
must!
• The provision of access related policies and procedures such as for obtaining
signers and for identifying access coordinators. To me, best practices are not
maximums but rather successful ways to provide at least the minimum access. If
more than the minimum is provided that is great. For example a very well written
easily understood and artistic brochure or newsletter to inform users with
disabilities of the access policies and procedures or the location of accessible
facilities is a best practice and may be used as a guide to others for providing
required access notification.
No, I disagree %
5 56%
• My same concern about the use of the term 'reasonable accommodation'
remains.
• I can go along with the statement that a best practice "includes" reasonably
accommodation individuals with disabilities if the sentence doesn't stop there. It
must explicitly state that reasonably accommodating someone by itself is not a
"best practice". Best practice must mean to go above a minimum requirement
to be an exemplary.
2. A best practice in accessibility includes accommodations based on research and
program outcomes about the needs of people with disabilities.
Yes, I agree %
5 56%
• At least part of the argument against this statement has been that it doesn't
provide for input of people with disabilities. First, good research and program
outcomes on accessibility would have to include people with disabilities.
Second, the statement only says "includes accommodations base on research
and program outcomes", it doesn't exclude anything else.
• BUT...it is not really an option. In other words, does this statement suggest that
accommodations do not need to be provided IF they are not based on research
and program outcomes?
No, I disagree %
4 44%
• I like the idea that customer feedback is what drives this...also don't use
accommodations here either...so I'd replace "research and program outcomes"
with "customer opinions and experiences"
• Yes, a best practice is to do research instead of flying by the seat of ones pants.
But, given the variation and diversity of people with disabilities the research
should acknowledge that what it can identify what works for most people but
not all people.
National Center on Accessibility Appendix E - 3
3. A best practice in accessibility includes phasing out adaptations when appropriate.
Yes, I agree %
4 44%
• Yes, there are some best practices that include phasing out adaptations.
No, I disagree %
5 56%
• The statement is too ambiguous and allows for interpretations that are clearly not
best practices.
• The best practice related to this should include the need to systematically
evaluate adaptations that are being provided to ensure that they are still
meeting needs.
• This statement does not mean anything when you add in the words "when
appropriate". I think it is meaningless and should be deleted, not because I
disagree but because it really does not convey anything.
4. A best practice in accessibility includes full survey of facilities, programs,
communication plans, and outreach on at least a five year basis.
Yes, I agree %
5 56%
• Many of our surveys are found to be incomplete and many of our newly
constructed facilities are found to not have met the required access design.
Regular periodic surveys are a must because of the many existing structural and
non-structural programs, which are not completely evaluated for appropriate
accessibility in the planning stage. This may be due to lack of knowledgeable
evaluators or lack of total resources.
• I'd replace "full" with "initial comprehensive" and am okay with this.
No, I disagree %
4 44%
• I agree with the other respondents who disagree. "Five years" seems arbitrary,
substituting "as needed" is too vague and to subjective, but the idea is, again,
that access isn't static, and that one must review, re-assess and revisit
accessibility of facilities and programs and communications plans and that the
timeframe is probably best determined on a case-by-case basis.
• For this to be true, it needs a qualifier to state that there is ongoing assessment (if
not a full survey). Maintenance of accessible features is an ongoing, day-to-day
responsibility.
5. A best practice in accessibility includes one person designated to have the
authority to provide, modify, and assist staff in provision of services and receive
complaints.
Yes, I agree %
5 56%
• Designating a person who would have responsibility for assuring programs and
facilities are accessible is a best practice.
• Not sure if it is "the best practice" but it is a common practice and sometimes the
envy of agencies that have nothing.
• Although I actually agree with the people who 'disagree' on this one -- I have to
say that in reality having at least one person (or one office) is very important.
Otherwise it is too easy for things to fall thru the cracks and not get done, or for
there to be no clear lines of authority at all to address accessibility.
• Make it one! Committees are great but every one of us has been on a work
committee that failed because of diluted authority.
No, I disagree %
4 44%
• I think that the authority should be dispersed. You need one person as an ADA
Coordinator but not only one person with authority to approve.
• This leaves too many loopholes: If the one person has the authority to provide
services and receive complaints but has no say in the design of programs,
activities, and facilities, or any say over budget, he/she cannot do the job. If it is
one person in a multi-faceted organization, how does he/she do it all? What
happens when that one person leaves?
• I don't understand why "the number of people" needs to be identified, since
typically in systemic and sustainable change, many individuals throughout the
agency may take on these responsibilities.
6. A best practice in accessibility includes integrating (as appropriate) information
about people with disabilities into the content of exhibitions, tours, and public
programs.
Yes, I agree %
7 78%
• Would an exhibit on Mt. Everest be complete without the inclusion of people with
disabilities who have reached the summit? Was the FDR Memorial complete
without the inclusion of FDR in a wheelchair?
• Yes, could be a best practice but would need to know more about the "how" this
is done.
• Yes.
• People with disabilities are part of society, history, and everyday life. One of the
most important aspects of exhibits is to allow the viewer to see him/herself in the
content. People with disabilities should be included positively and appropriately.
No, I disagree %
2 22%
• This seems a bit like tokenism. Why force or integrate information about disability
if it isn't germane to the display? If you mean accessible facilities and assistive
listening systems, sure, of course...but that's not the way this reads.